What changed for connected IPO research under FCA PS26/16?
From 5 August 2026 the FCA removed the seven-day wait between publication of the approved prospectus or registration document and the release of connected research, and dropped the requirement to give unconnected analysts the same information. One timing rule remains: research cannot go out until the relevant document is published. Any extra waiting period a bank applies is now its own policy, not law.
| When research can go out | How long records must be kept |
|---|---|
| Research must not be disseminated until the approved prospectus or registration document has been published under PRM 9.5 (COBS 11A.1.4F). The 7-day wait was removed on 5 August 2026 (PS26/16). | At least 5 years (SYSC 9.1.2R). The FCA may require up to 7 under the onshored MiFID Organisational Regulation. |
What do the United Kingdom rules say, and where does each come from?
FCA COBS 11A.1: connected research on UK IPOs
Until 5 August 2026 a syndicate bank had to wait seven days after the approved registration document or prospectus was published before releasing connected research, and had to give unconnected analysts the same information as its own. PS26/16 removed both. The timing rule that remains is COBS 11A.1.4F: a firm must not disseminate research on the issuer until the relevant document has been published under PRM 9.5. Engaging unconnected analysts is now a commercial choice. Banks that still run a delay do so as internal policy. FCA PS26/16 · COBS 11A.1
The prospectus regime from 19 January 2026
The Public Offers and Admissions to Trading Regulations (POATR) replaced the UK Prospectus Regulation, and the FCA’s PRM sourcebook replaced PRR. The amended COBS 11A.1 now cross-refers to PRM 1.4 and PRM 9.5, so "the document has been published" means published under PRM.
COBS 12.2 and 12.4, and SYSC 9: labelling, conflicts and record-keeping
COBS 12.2 separates independent investment research from non-independent research, which must be labelled a marketing communication. The issuer must not see a draft containing a recommendation or price target, and research staff must be separated from conflicted staff. COBS 12.4 requires disclosure of material conflicts. SYSC 9.1.2R sets a five-year record-keeping floor for MiFID business. The widely quoted seven years is not in SYSC 9; it comes from the onshored MiFID Organisational Regulation, under which the regulator may require up to seven. COBS 12.2 · SYSC 9
Not legal advice. Every figure above carries the instrument and provision it comes from, and links to the primary source; where we could not verify one, the text says so rather than guessing. Confirm your own obligations with your counsel or compliance team.
Last reviewed 5 October 2026
How United Kingdom compares with other jurisdictions
| Jurisdiction | When research can go out | How long records must be kept |
|---|---|---|
| India | A manager or co-manager must not publish research for 40 days after an IPO is priced, or 10 days after an FPO is priced (Research Analysts Regulations 2014, Reg. 18). There is no post-listing blackout in ICDR. Nothing outside the offer document may go to any group of investors or to a research analyst (ICDR Sch. IX(10)). | Merchant-banker records: 8 financial years (Merchant Bankers Reg. 16(1)). Insider-information database: 8 years (PIT Reg. 3(6)). Research-analyst records: 5 years (RA Reg. 25(2)). |
| United States | Regulation S: no selling effort aimed at the US. Under the SEC’s 1998 guidance, a website is not treated as aimed at the US if it names the countries it is meant for, excludes the US, and has procedures to prevent sales to US persons. Whether a waiting period applies depends on the offering’s Rule 902 category: none for Category 1, up to one year for Category 3. FINRA Rule 2241: a manager or co-manager must observe a quiet period of at least 10 days after an IPO and at least 3 days after a secondary offering. | Not stated. We have not verified the retention periods in SEC Rule 17a-4(e). |
| United Kingdom | Research must not be disseminated until the approved prospectus or registration document has been published under PRM 9.5 (COBS 11A.1.4F). The 7-day wait was removed on 5 August 2026 (PS26/16). | At least 5 years (SYSC 9.1.2R). The FCA may require up to 7 under the onshored MiFID Organisational Regulation. |
| European Union | No fixed waiting period at EU level. Research must be correctly labelled as research or as a marketing communication, with conflicts controls (Del. Reg. (EU) 2017/565 Arts. 36–37). A recommendation must carry the content and disclosures in MAR Art. 20 and Del. Reg. 2016/958. | 5 years; up to 7 if the regulator requests (MiFID II Art. 16(7) with 2017/565 Art. 76(8)) |
| Hong Kong | A manager, sponsor, listing agent or underwriter must not issue research for 40 days after an IPO is priced, or 10 days after a secondary offering is priced (SFC Code para. 16.5(g)). There is no pre-listing quiet period in the Code. | Not set in paragraph 16. Not yet verified elsewhere, so we quote none |
| Singapore | Not summarised. The commonly quoted Singapore rule rests on a secondary source: we could not confirm that SFA 2001 s.251(9) exists, and as reported it is a deadline to distribute before lodgement, not a blackout. We will summarise it once the section has been read in full. SFA 2001 | |
Common questions about the United Kingdom rules
What exactly did PS26/16 change, and when?
From 5 August 2026 the FCA removed two things: the seven-day wait after publication of the approved registration document or prospectus, and the requirement to give unconnected analysts equal access to information. What remains is COBS 11A.1.4F: no dissemination of connected research until the relevant document is published under PRM 9.5. Any day count a desk applies on top of that is now firm policy. Confirm against the policy statement with your counsel.
Does a UK bank still have to wait seven days before releasing connected research?
No. FCA PS26/16 removed the seven-day wait from 5 August 2026. Research still cannot go out before the approved prospectus or registration document is published (COBS 11A.1.4F). A bank may keep a longer wait as its own policy.
How long must UK research records be kept?
At least five years for MiFID business under SYSC 9.1.2R. The regulator may require up to seven years under the onshored MiFID Organisational Regulation.
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